Natural Resources Defense Council v. California Department of Transportation

Several environmental groups filed a lawsuit challenging California Department of Transportation’s approval of a new diesel truck expressway serving the Ports of Long Beach and Los Angeles, alleging that the final environmental impact report (EIR) pursuant to the California Environmental Quality Act did not, among other things, sufficiently address greenhouse gas emissions and associated climate change. The trial court denied the petition. On appeal, the appellate court affirmed, holding that the EIR adequately investigated and discussed the greenhouse gas impacts from the project, that the agency’s conclusion that the impacts would be “less than significant” was supported by substantial evidence, and that the agency was not required to make a quantitative analysis of greenhouse gas emissions in the EIR.